Privacy Policy

Last Updated: April 2025 | Version 1.0

This Privacy Policy explains how Servino-S collects, uses, stores, and protects the personal data of its users, in full compliance with the UK GDPR, EU GDPR (Regulation (EU) 2016/679), and other applicable data protection legislation.

1. About This Policy

This Privacy Policy applies to Servino-S -- a multi-platform business management application available on iOS, Android, and the Web (the "App", the "Service", "Servino-S"). It sets out how we, as the data controller, collect, use, share, retain, and protect personal data, and explains the rights available to you under data protection law.

By creating an account with Servino-S or using any of its features, you acknowledge that you have read and understood this Policy. If you do not agree with this Policy, you should not use the Service.

References to "we", "us", or "our" mean the legal entity operating Servino-S. References to "you" or "your" mean any individual whose personal data is processed by us -- including subscribers, business owners, workers, customers, and suppliers whose data is stored in the App.

2. Data Controller

The data controller responsible for your personal data is:

Product Name Servino-S
Legal Entity AUM PVT LTD, UK
Company Number 12535225
Privacy Contact info@servino-s.com
Website https://aumpvtltd.com/ and https://theservino.com/

If you have any questions about this Policy or wish to exercise your rights, please contact us using the details above.

3. What Personal Data We Collect

We collect personal data in the categories described below. We only collect data that is necessary and proportionate for the purposes described in Section 4.

3.1 Account and User Registration Data

When you register for Servino-S, we collect:

  • Full name
  • Email address (used as your primary login identifier)
  • Password (stored as a one-way bcrypt hash -- we never store plain-text passwords)
  • Mobile telephone number (optional -- used for SMS one-time passwords)
  • Google account details, if you register via Google OAuth (name, email, profile picture as provided by Google)

3.2 Business Profile Data

When you create a business within the App, we collect:

  • Business name, email address, and telephone number(s)
  • Business postal address (address lines, city, country, postcode)
  • Company registration number and registering authority (optional)
  • Business logo (uploaded image)
  • Website URL, Facebook page URL, Instagram profile URL (all optional)
  • VAT or tax reference numbers (optional)
  • Default document notes for quotations, invoices, and work orders

3.3 Partner Data (Customers, Workers, and Suppliers)

When you add contacts to your business, we collect information about:

  • Customers: Full name or business name, email address, mobile number, postal address
  • Workers: Full name, email address, mobile number, postal address, default pay rate and unit of measure
  • Suppliers: Full name or business name, email address, mobile number, postal address

Important: You are responsible for ensuring you have an appropriate legal basis for entering third-party personal data (such as your customers' and workers' data) into Servino-S. You act as a data controller in respect of that data, and we act as a data processor on your behalf. Please refer to Section 13 for further details on our processor responsibilities.

3.4 Sales and Financial Document Data

As part of the quotation, work order, and invoice management features, we process:

  • Customer names, addresses, and contact details as they appear on documents
  • Worker names and email addresses as assigned to work orders
  • Item descriptions, quantities, prices, discounts, tax rates, and totals
  • Document status, dates, and reference numbers
  • Payment amounts, due dates, and payment history

3.5 Expense and Mileage Data

When you use the Expenses module, we collect:

  • Mileage records: vehicle registration number, start and end addresses, postcodes, start and end date/time, total distance travelled, and unit of measure
  • GPS/location data: precise geographic coordinates collected via your device's location services when you use the GPS tracking feature in the Mileage Recording module. Location data is used solely to calculate your route distance and is not used for any other purpose
  • Supplier invoice details: supplier information, invoice amounts, payment status, expense categories, and notes
  • Other expense records: expense type, date, amount, and free-text notes

3.6 Technical and Usage Data

We automatically collect certain technical data when you use the Service:

  • IP address and device identifiers
  • Device type, operating system, and browser type
  • App version and platform (iOS, Android, Web)
  • Authentication tokens (Firebase/JWT -- not permanently stored in a readable form)
  • Log data: API request timestamps, error reports (via Sentry), and uptime monitoring data
  • Offline sync queue data: temporarily stored in a local SQLite database on your mobile device until synced to our servers

3.7 Communications Data

If you contact us for support or via email, we will collect your name, email address, and the content of your communication.

4. How and Why We Use Your Personal Data

We process personal data only where we have a lawful basis to do so under Article 6 of the UK/EU GDPR. The table below summarises our purposes and the corresponding legal bases.

Purpose of Processing Personal Data Used Legal Basis (Art. 6 GDPR)
Account creation and authentication Name, email, password, mobile number, Google profile Art. 6(1)(b) -- Performance of a contract
Providing core business management features (quotations, work orders, invoices, expenses) All partner, item, financial, and mileage data Art. 6(1)(b) -- Performance of a contract
GPS-based mileage tracking Precise location coordinates, vehicle registration Art. 6(1)(a) -- Consent (permission requested at device level)
Sending transactional emails and document notifications Email address, document content Art. 6(1)(b) -- Performance of a contract
Providing offline data storage and synchronisation All operational data, offline sync queue Art. 6(1)(b) -- Performance of a contract
Analytics dashboards and financial reporting Aggregated financial data scoped to your business Art. 6(1)(b) -- Performance of a contract
Security: preventing fraud, account lockout, intrusion detection IP address, login attempts, authentication tokens Art. 6(1)(f) -- Legitimate interests
Technical monitoring, error tracking, uptime monitoring Log data, IP addresses, error reports Art. 6(1)(f) -- Legitimate interests
Responding to support requests Name, email, communication content Art. 6(1)(f) -- Legitimate interests
Legal and regulatory compliance Any data required by applicable law Art. 6(1)(c) -- Legal obligation
Subscription and billing management (future feature) Name, email, billing details Art. 6(1)(b) -- Performance of a contract

Where we rely on legitimate interests (Article 6(1)(f)), we have conducted a balancing test and are satisfied that our interests do not override your fundamental rights and freedoms. You may request a copy of our legitimate interests assessment by contacting us.

5. Location Data and GPS Tracking

The Servino-S mobile application includes a GPS-based mileage tracking feature that records your location when you tap "Start Tracking" and stops recording when you tap "Stop Tracking". This feature:

  • Requires your explicit consent via your device's operating system permission dialogue before location data is accessed
  • Is used solely to calculate the distance between your start and end points for business mileage records
  • Does not continuously monitor your location in the background when not actively tracking a journey
  • Stores only the start address, end address, and total distance -- precise GPS coordinates are not permanently stored on our servers after the journey calculation is complete
  • Is not available on the Web portal; it is a mobile-only feature

You may revoke location permissions at any time through your device settings. Revoking this permission will disable GPS-based mileage tracking, but you can continue to enter mileage data manually.

6. Data Sharing and Third-Party Processors

We do not sell, rent, or trade your personal data to any third party for marketing purposes. We share data only in the limited circumstances set out below.

6.1 Sub-Processors

We engage the following trusted third-party service providers (sub-processors) to help us deliver the Service. Each has been assessed for GDPR compliance and is bound by contractual data processing obligations:

Service Provider Service Data Shared Location
Google Firebase User authentication, OAuth sign-in, access tokens Email, name (OAuth), auth tokens EU / USA (SCCs)
Hostinger VPS Application hosting and database (MySQL) All application data EU (Lithuania)
SendGrid (planned) Transactional email delivery Email address, document attachments USA (SCCs)
WhatsApp Business API (plan.) Document sharing notifications Phone number, document links USA (SCCs)
Stripe / Razorpay (planned) Subscription payment processing Name, email, billing info USA / India (SCCs)
Sentry Error monitoring and crash reporting Log data, device info, anonymised stack traces USA (SCCs)
Uptime Robot Availability monitoring Server IP, response time (no personal data) USA
GitHub Actions (CI/CD) Deployment pipeline Source code only -- no personal data USA (SCCs)
Redis / Celery Background task processing (self-hosted on VPS) Temporary task queues EU (Hostinger VPS)

6.2 Legal Disclosures

We may disclose your personal data to competent authorities, regulators, law enforcement agencies, or courts if we are under a legal obligation to do so, or if necessary to protect the vital interests of a person, or in connection with legal proceedings.

6.3 Business Transfers

In the event of a merger, acquisition, or sale of all or a portion of our business assets, your personal data may be transferred to the acquiring entity. We will provide notice before your personal data is transferred and becomes subject to a different privacy policy.

7. International Data Transfers

Some of our sub-processors are located outside the United Kingdom and the European Economic Area (EEA), including in the United States. Where we transfer personal data internationally, we ensure appropriate safeguards are in place to protect your data to the same standard as it is protected within the UK/EEA. The safeguards we rely upon include:

  • Standard Contractual Clauses (SCCs) approved by the European Commission and the UK International Data Transfer Agreement (IDTA)
  • Adequacy decisions made by the UK Government or European Commission for recipient countries

You may request further information about the specific safeguards in place for any particular transfer by contacting us at the address in Section 2.

8. How Long We Keep Your Data

We retain personal data only for as long as is necessary to fulfil the purpose for which it was collected, or to comply with legal, regulatory, or contractual obligations. The retention periods below represent our standard practice:

Category of Data Retention Period Reason
Account data (name, email, mobile) Duration of account + 2 years after account deletion Legal obligation and resolution of disputes
Business profile data Duration of active subscription + 2 years Legal and tax record requirements
Customer, Worker, and Supplier data Duration of account + 2 years after account deletion Contractual and legitimate business records
Financial documents (invoices, quotations, work orders) 7 years from document date Legal/tax obligation (HMRC -- UK, or equivalent)
Expense and mileage records 7 years from date of entry Tax and HMRC mileage compliance requirements
GPS/location coordinates Deleted immediately after route calculation Data minimisation (GDPR Art. 5(1)(e))
Technical/log data 90 days on a rolling basis Security monitoring and debugging
Backups 30 days (automated daily backups) Business continuity
Support communications 3 years Legitimate interests (dispute resolution)

After the applicable retention period expires, we securely delete or anonymise personal data so that it can no longer be attributed to any individual.

9. How We Protect Your Data

We take the security of your personal data seriously and implement appropriate technical and organisational measures to protect it against unauthorised access, accidental loss, alteration, or disclosure.

9.1 Technical Measures

  • All data transmitted between the App and our servers is encrypted using HTTPS/TLS 1.2 or higher
  • All data stored on our servers is encrypted at rest using AES-256 encryption
  • Passwords are hashed using bcrypt with a minimum cost factor of 12 -- we never store passwords in plain text
  • Authentication uses short-lived JWT access tokens (15-minute expiry) combined with 7-day rotating refresh tokens via Firebase
  • Multi-factor authentication (MFA) via SMS one-time passwords is available and recommended
  • Account lockout after 5 consecutive failed login attempts, with unlock via verified email link
  • SQL injection and common web application attacks are mitigated through parameterised queries and server-side input validation
  • Multi-tenant data isolation: each business's data is logically separated using unique business identifiers -- no user can access another user's data

9.2 Organisational Measures

  • Access to production systems is restricted to authorised personnel only
  • Automated daily database backups with 30-day retention
  • Continuous application monitoring via Sentry (error tracking) and Uptime Robot (availability monitoring)
  • Regular review of sub-processor security practices

While we implement strong security measures, no system is completely immune from security risks. In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, we will notify you and the relevant supervisory authority as required by law (within 72 hours of becoming aware of the breach).

10. Your Rights Under Data Protection Law

Under the UK GDPR and EU GDPR, you have the following rights in respect of your personal data. These rights apply to personal data we hold about you as a data subject in your own right (e.g. your account data). Where you have uploaded third-party data (e.g. your customers) into Servino-S, those individuals must exercise their rights with you as the data controller of that data.

Your Right What It Means How to Exercise
Right of Access (Art. 15) You may request a copy of all personal data we hold about you, along with information about how it is processed. Submit a Subject Access Request (SAR) to privacy@servino-s.com. We will respond within one month.
Right to Rectification (Art. 16) You may request correction of inaccurate or incomplete personal data. Contact us by email or update data directly in the App settings.
Right to Erasure -- "Right to be Forgotten" (Art. 17) You may request deletion of your personal data where there is no overriding legal basis for continued processing. Email privacy@servino-s.com. Note: some data may be retained where required by law (e.g. financial records).
Right to Restriction of Processing (Art. 18) You may ask us to temporarily suspend processing of your data -- for example, while accuracy is contested. Email privacy@servino-s.com specifying the restriction requested.
Right to Data Portability (Art. 20) You may request your data in a structured, machine-readable format (e.g. CSV/JSON) for transfer to another service. Submit a portability request to privacy@servino-s.com. Data will be provided within one month.
Right to Object (Art. 21) You may object to processing based on legitimate interests. We will cease processing unless we can demonstrate compelling legitimate grounds. Email privacy@servino-s.com stating the grounds for your objection.
Right to Withdraw Consent (Art. 7(3)) Where processing is based on your consent (e.g. GPS location access), you may withdraw consent at any time without affecting the lawfulness of prior processing. Revoke location permissions in your device settings, or contact us to withdraw any other consent-based processing.
Rights re: Automated Decisions (Art. 22) You have the right not to be subject to decisions based solely on automated processing that produce legal or similarly significant effects. Contact us if you believe you have been subject to such a decision.

To exercise any of these rights, please contact us at privacy@servino-s.com. We will respond within one calendar month of receiving your request. We may need to verify your identity before processing your request. There is no charge for most requests, though we reserve the right to charge a reasonable fee or refuse requests that are manifestly unfounded or excessive.

If you are not satisfied with how we have handled your request, or with our data protection practices generally, you have the right to lodge a complaint with the relevant supervisory authority:

  • United Kingdom: Information Commissioner's Office (ICO) -- www.ico.org.uk
  • European Union: The data protection authority in your EU member state of habitual residence or place of work

11. Cookies and Local Storage

11.1 Web Portal Cookies

The Servino-S web portal may use cookies and similar tracking technologies to operate the Service. Cookies we use include:

Cookie Name Type Purpose Expiry
auth_token Strictly Necessary Maintains your authenticated session Session / 7 days
csrf_token Strictly Necessary Protects against cross-site request forgery Session
app_preferences Functional Stores UI preferences (language, theme) 1 year
_ga, _gid (future) Analytics Anonymous usage analytics (if enabled in future) 2 years / 24 hours

We will obtain your consent before placing any non-essential cookies (e.g. analytics cookies). You may manage or disable cookies through your browser settings, though disabling essential cookies may impair the functionality of the web portal.

11.2 Mobile App Local Storage

The Servino-S mobile application uses a local SQLite database on your device to store operational data and an offline sync queue. This local database:

  • Stores your business data locally to enable offline operation
  • Assigns temporary local identifiers to records created offline (prefixed "LOCAL-"), which are replaced with permanent server IDs upon synchronisation
  • Is protected by your device's built-in security (device encryption and access controls)
  • Is not shared with any third party directly

12. Children's Privacy

Servino-S is a business management application intended solely for use by individuals aged 18 and over. We do not knowingly collect or process personal data from children under the age of 18. If we become aware that we have inadvertently collected personal data from a child under 18, we will delete it promptly.

If you believe that a child under 18 has provided us with personal data, please contact us immediately at privacy@servino-s.com.

13. Servino-S as a Data Processor

When you use Servino-S to store and manage data about your own customers, workers, and suppliers, you are acting as the data controller in respect of that third-party personal data. Servino-S acts as a data processor on your behalf, processing that data only in accordance with your instructions and this Policy.

As the data controller of your customers' and workers' data, you are responsible for:

  • Ensuring you have a lawful basis for entering that personal data into Servino-S
  • Providing those individuals with appropriate privacy notices about how their data is used
  • Responding to any data subject rights requests made by those individuals
  • Ensuring the accuracy and security of the data you enter

Our Data Processing Agreement (DPA), which governs the terms on which we process personal data on your behalf, is incorporated by reference into our Terms of Service. By using Servino-S, you agree to the terms of the DPA. A copy is available on request.

14. Automated Decision-Making and Profiling

Servino-S does not currently make any decisions about individuals that are based solely on automated processing and that produce legal or similarly significant effects. Our analytics and reporting features aggregate financial data for your own business insight -- they do not generate automated decisions about you or any third party.

If we introduce any automated decision-making in the future, we will update this Policy and implement appropriate safeguards.

15. Marketing Communications

We may send you occasional service-related communications (e.g. important updates about the Service, security notifications, or changes to this Policy). These are necessary for the performance of the contract and cannot be opted out of while you maintain an account.

Where we wish to send you marketing or promotional communications (e.g. new feature announcements, product updates), we will do so only with your prior consent and in accordance with the UK Privacy and Electronic Communications Regulations (PECR). You may opt out of marketing communications at any time by clicking the unsubscribe link in any marketing email, or by contacting us at privacy@servino-s.com.

16. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our data processing practices, the services we offer, or applicable laws and regulations. When we make material changes, we will:

  • Post the updated Policy on our website with a revised "Last Updated" date
  • Notify you by email at the address associated with your account, or through an in-app notification, at least 30 days before the changes take effect

Your continued use of Servino-S after the effective date of the updated Policy constitutes your acceptance of the changes. If you do not agree with the updated Policy, you should cease using the Service and delete your account.

The version history of this Privacy Policy is maintained internally. Previous versions are available on request.

17. Contact Us and Complaints

If you have any questions, concerns, or complaints about this Privacy Policy or about how we process your personal data, please contact our Data Protection representative:

Email privacy@servino-s.com [placeholder]
Post [INSERT COMPANY NAME], [INSERT ADDRESS]
Subject line Privacy / Data Protection Enquiry

We will acknowledge your contact within 5 business days and aim to resolve all queries within one calendar month.

If you are not satisfied with our response, you have the right to lodge a complaint with the Information Commissioner's Office (ICO), the UK's supervisory authority for data protection:

ICO Website www.ico.org.uk
ICO Helpline 0303 123 1113
ICO Post Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF

If you are located in the European Union, you may additionally lodge a complaint with the data protection authority in your country of residence or place of work.

Glossary of Key Terms

Term Definition
Data Controller The entity that determines the purposes and means of processing personal data.
Data Processor An entity that processes personal data on behalf of a data controller.
Data Subject The individual to whom personal data relates.
GDPR General Data Protection Regulation -- EU Regulation 2016/679 (and UK GDPR as retained in UK law).
ICO Information Commissioner's Office -- the UK's independent data protection regulator.
Personal Data Any information relating to an identified or identifiable natural person.
Processing Any operation performed on personal data, including collection, storage, use, disclosure, or deletion.
SCCs Standard Contractual Clauses -- EU-approved contractual mechanisms for international data transfers.
Sub-processor A third party engaged by the data processor to assist in processing personal data.
UK GDPR The UK's retained version of the EU GDPR, as amended by the Data Protection, Privacy and Electronic Communications Regulations 2019.

© 2026 Servino-S. All rights reserved. | This document should be reviewed by a qualified legal professional before publication.